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I've seen the HSE alert and they have taken the new guidance for mild steel fume and applied it to all welding (regardless of metal type). RPE will be required at all times as there is no safe level for carcinogens

What ever happened to a risk based approach, where's the evidence for other types of metal welding causing cancer.

I came across this yesterday, its going to have a big effect on a lot of companies. I used to work for a fabrication company and at one point we had almost 200 welders. Around 150 were on short term contract for an oil and gas project. With powered respirators costing between 400 to 1000 each that would have been a game changing figure.

On another note the statement within the alert that there is no safe level of exposure is a bit worrying.

The bulletin states engineering controls then RPE as an additional item if the engineering control in not suffiecient, so my question is RPE on its own sufficient ? Or are we definatly looking at having to buy a portable LEV machine ? (i'm taking a worshop enviroment using an oxy set up for maybe 20 minutes in total over the working week)

Also does to term also cover cutting a siezed bolt or heating a siezed nut in order to aid its removal here ?

The main risk is from the mild steel vapourizing from the heat then condensing in the air (creating the fumes). These condensed particles are small enough to enter deep into the lungs. Basically if the mild steel is heated up beyond its melting point you will need to take precautions.

I am in the same boat though. We rarely weld (1 hour per week max), so we have never had LEV installed for this (only been with this company for 7 months). Currently this is done in a very airy factory (surrounded by a screen) and the welders wore FFP3 disposable masks. The wording of the HSE seems to suggest that if the welding is inside LEV will be expected, however outside it my be ok with just face masks.

My thoughts are taking me down same road, LEV indoors a must which we have already and mask or air fed helmit for outside work, we are in same sittuation where there is not a great deal of weldding done (1-2 hours per week)

What are others thoughts here ???

I still feel there is a massive implication here for the industry yes in a good way but fearfull as mentioned previously smaller companys my not take notice or even be aware of the safety alert.

We have a similar situation, as a plant hire business we do very little in the way of welding and this was done in a large workshop with lots of ventilation and the welder wearing suitable RPE. Having read the recent information from the HSE on welding we looked at the sitiation and have decided to install a purpose built welding booth complete with a portable LEV unit. This will allow us to carry out the normal day to day welding and the little bit of fabrication we do and if there is a bigger bit of work to do on an item of plant we can wheel the LEV to the job and couple with some RPE do the welding. The issue of occupational helaht screening does not apply to us as we already do it as a matter of course as part of the package covering noise, vibration etc.

I work in a large Fab shop with around 15 welding bays, it's going to cost a small fortune to fit LEV, but we'll be doing it anyway. The bigger concern for me is the future of the industry.

1) It is hard enough finding younger workers willing to do hard, hot, heavy and noisy work when they can get similar money in a nice cosy call centre now we are going to have to tell them that the hard, hot, heavy and noisy industry causes cancer!

2) Wait til the no win no fee mob get hold of this "Have you or a member of your family worked in the welding industry? Have you or they had lung cancer? we can win you thousands in compensation etc..."

My interpretation is that any welding in the open air should be fine with basic RPE. But in the main, our welding is conducted in a marsden shed. We have several production lines all doing their thing. The issue is we case harden the blades by welding over them. This means that the welder is operating for several hours in a working day. I'm now looking at replacing the current powered RPE for more effective and modern kit. We only have 2 welders so not a huge outlay. But money we don't really want to be spending.

We already have LEVs for welding but, being a belt and braces organisation, we will be introducing airfed masks. We plan to use positive airfed masks so that face fit is not required. We feel this will be more comfortable for the users and, with the LEV already in place, will give sufficient protection.

Can i just make the point that no legislation has changed, no guidance has changed with repect to weld fume. What has happened is that EH40 has been updated and Chromium VI has been classified as a carcinogen. The rush to invest in air fed helmets is absolute folly. Each individual area of welding needs to have its own COSHH assessment.

For example if you are welding Mild steel using FCAW or MIG this is predominantly a trivalent reaction and gives off Chromium II which if you look in EH40 the WEL is 0.5 mg/m3. We sample on a regular basis and get indicitive readings generally of 0.0006mg/m3. if you then stuck someone in a PFF3 at a APF of times 20, that in theory gives you protection to a theoretical value of 10mg/m3 so why would you buy an air fed.

Then take the scinario if you were welding mild steel using MMA then this would create Chromium VI which is a hexavalent reaction, and, as noted has been redesignated a carcinogen with a WEL of 0.05mg/m3. Given you get the same indicative readings of 0.0006mg/m3 then this is way below the WEL and you would be legally compliant to utilise PFF3 protection.

In all scenarios you really need to try to facilitate engineering controls where possible. But to just go for air fed is ludicrous. If you look at the example above you would simply say use MIG where possible. As I said its about the assessment.

The best way if you are in a workshop of keeping the team safe is to utilise flexible LEV and make sure the team know how to fully make use of it and extract the full plume. That way they should get 0mg/m3 of anything so why on earth would you give them an air fed mask as well.

We have LEV of course, had it for decades but sometimes I know it is not used because it can be counterproductive to the actual welding process - ie, if the hood is too close or the LEV too powerful it removes some of the gas required to make a good weld and you end up with rubbish which then needs redoing leading to more welding fumes and rework.

We also have urine tests carried out once a year to check for heavy metals and manganese and participated in a 4 week study with HSL on welding fumes and bodily absorption. I know our employees are well looked after already and some might argue that airfed is not necessary. Maybe it is and maybe it isn't, but we are an organisation that seeks to always do the right thing - belt and braces so that we have a good safety culture and the employees know we will do whatever is necessary to keep them safe. As it happens, we only have two welders so the cost will be easily affordable but what price do you put on morale, involvement, culture, buy in?

Sometimes taking a positive step like this is so much more than just introducing an airfed mask.

Can i just make the point that no legislation has changed, no guidance has changed with repect to weld fume. What has happened is that EH40 has been updated and Chromium VI has been classified as a carcinogen. The rush to invest in air fed helmets is absolute folly. Each individual area of welding needs to have its own COSHH assessment.

For example if you are welding Mild steel using FCAW or MIG this is predominantly a trivalent reaction and gives off Chromium II which if you look in EH40 the WEL is 0.5 mg/m3. We sample on a regular basis and get indicitive readings generally of 0.0006mg/m3. if you then stuck someone in a PFF3 at a APF of times 20, that in theory gives you protection to a theoretical value of 10mg/m3 so why would you buy an air fed.

Then take the scinario if you were welding mild steel using MMA then this would create Chromium VI which is a hexavalent reaction, and, as noted has been redesignated a carcinogen with a WEL of 0.05mg/m3. Given you get the same indicative readings of 0.0006mg/m3 then this is way below the WEL and you would be legally compliant to utilise PFF3 protection.

You seem knowledgable on this, but you have me confused. Whilst I can agree that no legislation or guidance has changed, the HSE state:

"There is a change in HSE enforcement expectations in relation to the control of exposure of welding fume, including that from mild steel welding."

Which would seem to indicate that something has changed. It is vague, hence why we are having this discussion, to clarify what this means.

And we also have:

"Regardless of duration, HSE will no longer accept any welding undertaken without any suitable exposure control measures in place, as there is no known level of safe exposure."

I am just about to embark on my NVQ level 5 so I am sure I still have a lot to learn, but how am I supposed to know the WEL limit when I read that statement from the HSE? It also suggests that they were willing to accept our current setup before this statment. Currently we have been relying on a well ventilated area and FFP3 disposable masks (with a face fit test of course). We just didn't weld enough to deem LEV practicable, now we are unsure if that is still enough.

This has come about because of a "domain knowledge report" by the by the IARC which has said that weld fume [that specifically means gaseous and dust constituent] causes cancer. If you as a business are monitoring exposure to weld fume then you will be aware that there are several constituent parts of "weld fume" that are carcinogenic such as cadmium, colbolt, Chromium VI, and others that are listed in EH40 table 1 such as copper, vandium, zinc, lead so the type of controls now recommended by the HSE really should be in place anyway.

The big issue for me is they have just said "weld fume" and have not assigned it a WEL....I presume this is because it is made up of all of the above, and made up of things that already have WELs.

Again it all depends on what your welding. Me personally I would get some monitoring done when you are welding and if it is well ventilated you should pick very small amounts of constituents...the monitoring will enable you to analyse.

1. What is actually in your particular weld fume.

2. What levels you are getting with the ventilation you have.

3 You can then compare the consituent levels with what is given in EH40 and see if the PF3 is sufficient.

Example- but short your monitoring pickes up vandium @ 0.0006 mg/m3 and chromium II @ 0.005mg/m3 and lead at 0.005mg/m3 then PF3 when you look at the WELs of these substances suggest this is okay. If they are higher than the WEL or close that would be a judgement call you would need air fed.

Can i just make the point that no legislation has changed, no guidance has changed with repect to weld fume. What has happened is that EH40 has been updated and Chromium VI has been classified as a carcinogen. The rush to invest in air fed helmets is absolute folly. Each individual area of welding needs to have its own COSHH assessment.

For example if you are welding Mild steel using FCAW or MIG this is predominantly a trivalent reaction and gives off Chromium II which if you look in EH40 the WEL is 0.5 mg/m3. We sample on a regular basis and get indicitive readings generally of 0.0006mg/m3. if you then stuck someone in a PFF3 at a APF of times 20, that in theory gives you protection to a theoretical value of 10mg/m3 so why would you buy an air fed.

Then take the scinario if you were welding mild steel using MMA then this would create Chromium VI which is a hexavalent reaction, and, as noted has been redesignated a carcinogen with a WEL of 0.05mg/m3. Given you get the same indicative readings of 0.0006mg/m3 then this is way below the WEL and you would be legally compliant to utilise PFF3 protection.

In all scenarios you really need to try to facilitate engineering controls where possible. But to just go for air fed is ludicrous. If you look at the example above you would simply say use MIG where possible. As I said its about the assessment.

The best way if you are in a workshop of keeping the team safe is to utilise flexible LEV and make sure the team know how to fully make use of it and extract the full plume. That way they should get 0mg/m3 of anything so why on earth would you give them an air fed mask as well.

I am not sure that I entirely agree on this point. The
minute that product is confirmed a carcinogen all things change.

I refer to section 49 of EH40 which includes a requirement
that exposure of carcinogenic and mutagenic substances be reduced to as low as
is reasonably practicable. This provision extends to section 7(5) and (7) of
COSHH and in particular the COSHH ACoP.

E R I C P D
why the wailing hands about beards and RPE - the duty has always been about protection
spend wisely even on the eve of Brexit changes to the Carcinogens Directive and the shift of OEL determination to ECHA means those who seek to conduct a Cheapest Available Technology will only be storing future liability
Get it right first time through the heirarchy even if it means outsourcing to more suitably equipped providers

Great to have the input so far , however this has put me straight back to square one...... according to this email which I recieved today via the HSE bulletin , on page 21 it states "No LEV = IN , consider PR (should that be PN?)"

Then goes on to say by supplying " RPE only / IN / Fume not being controlled in accordance with the hierarchy of control and COSHH priciples of good control practice."

We also only do very small amounts of welding, measured in minutes a week and have up until this guidance relied on natural ventilation. I think not only training about welding fume is necessary, but also the use of the LEV so it will not suck all your shielding gas away, is going to be required.

We will need a portable unit as when we do weld it will not be at a workbench, and may include vertical and overhead welding (MMA, MIG and Gas cutting). Does anyone have any recommendations for extraction equipment that is portable and could be configured to the above weld positions? A quick initial look seems to show Prices 1.5 to 2 thousand pounds, which seems a bit steep (we have 12 locations, so over £20K – MD will not be happy).

So, any recommendations for portable equipment, not necessarily the cheapest going so it does not fall apart on day 2, but also not the Rolls Royce version either as we don’t do a lot. Or if no recommendation what are you looking at.

I can see a lot of smaller companies falling foul of this, especially something small car garages and the like who probably don’t do much and may just wait for the improvement notice and then just stop welding. This should be interesting how this pans out.

EH40 ACOP 49 does indeed say what you said it does but the words here are "reasonably practicable". Can I give you an example. We weld inside boilres and do extensive fume monitoring. The indicative readings for say Cobalt in the weld fume is 0.0006 mg/m3 which is well below the WEL [which is 0.1mg/m3] in table 1 of EH40. If you put a person in a PFF3 with an protection factor of 20 at £2.00 then the risk is managed more than sufficiently. If you put him in an air fed that protection factor goes up to 40 at £1200 you get not a lot more bang for your buck. Where you were in a confined space with no monitoring data and practically you knew that you could expect hexavalent reaction and the production of high levels of Chromium VI then the air fad would be requisite.

Its all about having data around you welding operational fume make and a salient, suitable, sufficient risk assessment. The point I am making is that you dont automatically need to put everyone in air fed helmets when you cannot get sufficent engineering controls.

Its all about having data around you welding operational fume make and a salient, suitable, sufficient risk assessment. The point I am making is that you dont automatically need to put everyone in air fed helmets when you cannot get sufficent engineering controls.

Hope this makes sense.

Thanks for further clarification. Probaby a rookie question but since we don't deal with any chemicals (in any large quantities) in my work place with WELs I am a bit embarrassed to admit we don't have any air quality monitoring. What would you suggest is the best way for us/me to go forward on this? Would it be an external company, or is there a monitoring decive you can recommend?

Thanks for further clarification. Probaby a rookie question but since we don't deal with any chemicals (in any large quantities) in my work place with WELs I am a bit embarrassed to admit we don't have any air quality monitoring. What would you suggest is the best way for us/me to go forward on this? Would it be an external company, or is there a monitoring decive you can recommend?

in the same boat as you , was just wondering which option was best whether to add it to the Occy heath persons list or investment into a meter.

If you put a person in a PFF3 with an protection factor of 20 at £2.00 then the risk is managed more than sufficiently. If you put him in an air fed that protection factor goes up to 40 at £1200 you get not a lot more bang for your buck.

Agreed, but don’t forget the cost of the fit testing for a mask and the ongoing hassle of enforcing them being clean shaven. If it is one man (or Woman) who is the welder and needs to be clean shaven, they are a good employee and you risk losing them, then £1,200 may not be quite so bad.

Great to have the input so far , however this has put me straight back to square one...... according to this email which I recieved today via the HSE bulletin , on page 21 it states "No LEV = IN , consider PR (should that be PN?)"

Then goes on to say by supplying " RPE only / IN / Fume not being controlled in accordance with the hierarchy of control and COSHH priciples of good control practice."

My thoughts from all the information I have managed to find and sorce from HSE website and other sites are still along the line of indoors LEV seems to be a must where previously the use of RPE alone would have been acceptable, Outdoors RPE a must with the consideration of a LEV where practical, as always your risk assessment and any monitoring will inform you of what steps you should take.

If you PM me and I will ring you and take you through EH40 and the WEL system.

The HSE are right there is no known safe level of exposure but if you look in EH40 carcinogens are assigned WELs - which are allowable percentages of a hazardous substances in a workplace atmosphere...even carcinogens have them. Its about knowing the WEL and being able to prove you are protecting the individual.

I refer to this: "Regardless of duration, HSE will no longer accept any welding undertaken without any suitable exposure control measures in place, as there is no known level of safe exposure"
I fail to see how you can have exposure control measures if you have no idea what you have to control against!
Practically all providers of welding consumables provide the relevant information about fumes emitted.
Fume content can be measured in the workplace, at a cost.
This should not really be any surprise to anyone in the welding industry, welding fume has long been associated with a variety of respiratory diseases, so has it's association with cancer. This just expands the previously existing knowledge.
Sorry about all the work needed to protect the workforce...but 40 years ago I was welding 50mm steel plate with CO2/flux-cored-wire...and my employer provided fume extraction on the weld torch head and a moveable extraction hood (all the small fabrication bays had LEV).
40 years ago guys...

Thank you all for your interpretations, if the HSE are now saying that they will not accept ANY welding without controls, where does that put the average self-employed garage owner, farmer, even sculptor? If you encounter a farmer who occasionally welds up a broken gate using an oxyacetylene rig, is he OK to carry on doing so outside with a PFF3 mask standing upwind? Or a garage mechanic who once in a while welds up a sill with a MIG, again no LEV just a PFF3 mask in a well-ventilated garage?

Does this now mean that to comply with the HSE advice they must either give up those activities or have exposure testing performed and then buy a portable LEV? That does not seem proportionate but I need a solution that the HSE would accept (if you get my drift)

Whilst I am supportive of the INTENTION of this HSE Alert, I am cynical about how it will result in enforcement in practice, especially as regards any welding fumes where there are not specific Workplace Exposure Limits in place.

To serve an Improvement Notice, an Inspector has to be of the opinion that there has been breach of legislation.

What opinion are they going to present as regards sporadic welding in the open air or in a relatively open workshop?

Presumably failure to ensure "adequate control" of exposure.

So, when it comes to an appeal against an Improvement Notice what evidence will HSE adduce to demonstrate that the Inspector was justified in coming to their opinion?

Are front line Inspectors going to be provided with the right air monitoring equipment + the facility to use these without endangering those carrying out welding or working in the vicinity?

Or are they going to rely on Specialist Occupational Hygiene Inspectors looking at some photos and statements setting out the time extent of welding and environmental conditions at EACH location covered by each notice?

This is all heavily dependent on having enough front line Inspectors - far fewer than there used to be PLUS enough Occupational Hygiene specialists - there were never enough of these, even before HSE pushed health issues up its agenda.

Decades ago a Principal Inspector instilled me with the principle that if, as an Inspector, you were going to push the boundaries of what legislation required, you should do it via Prosecution, NOT notice, where the potential costs of litigation following successful appeal against a notice, as regards all the consequential losses resulting from the issue of a notice could be very considerable.

To those who say that as mild steel welding fume is now officially classified as carcinogenic and thence there is no safe limit, this doesn't wash on the "adequate control" bit of the opinion as we have WELs for numerous carcinogens - thence the "reasonably practicable" part of the legislative requirement is always going to come into the argument in a Tribunal considering an appeal against a notice, or in the Court considering a prosecution.

The legislation may put the onus on the defendant to prove somethings are not reasonably practicable, but there comes a point where HSE will need to try and rebut (at least in part) what the defence puts forward.

....and to date HSE's attempts to do health blitz campaigns have rather fallen apart, especially in construction where the subsequent press releases have confirmed that the number of Prohibition Notices for safety matters have vastly outnumbered the number of Improvement Notices for health risks.

I understand that an Inspector cannot ignore a blatantly dangerous scaffold when doing a health risk blitz, but if they insist on writing out a PN, rather than quietly agreeing with a contractor NOT to use that scaffold until it is safe and then concentrate on the IN for the health risks, the subsequent press release would be much more likely to send the intended message.

But in the era of Fee For Intervention, can we expect that quiet word instead of a PN?

If you look at the link kindly provided in #24, what the inspector will look for is there LEV and if there is LEV, is there any visible fume escaping. I guess they will also ask for any expensive monitoring to prove everything is ok.

Extract from document

The control measure(s) will be dependent on the task, as there is no one control solution that will be effective for all cases. The exposure controls required will be:

the provision of suitable engineering controls e.g. LEV for all welding fume inside, with RPE for any residual fume; and

the provision of appropriate RPE for welding outdoors.

HSE will no longer be accepting short-duration work without any appropriate exposure control.

HSE accept that looking for residual fume is not a 100% effective way of assessing residual risk, as not all fume is visible. However, this is a ‘rule of thumb’ pragmatic solution.

So, if you weld or flame cut inside even for 2 minutes a week (garage mechanic welding a exhaust bracket back on easily less than 2 minutes welding), then they expect to see LEV (even if the set is in the corner not being used). If there is any hint of fume escaping when they arrive then they will also expect to see RPE. And if they don’t see what they expect then IN.

Outside ie the farmer welding the cross bar back on a gate, again 2 minutes then they expect to see RPE and apparently IN.

Air sampling, that’s fine if you are on some sort of production line or specific welding booth, but ad hoc welding around a factory by maintenance personnel, or a garage mechanic who may have lie on their back to and weld overhead one minute and at a bench the next is pointless IMHO, it will never really be representative.

I looked into LEV last week, and although you can get two sorts of portable LEV one which extracts and filters the air back into the workplace. Which will require the ongoing purchase of filters and then the cost of disposal of filters (Hazardous?). The other option is LEV output outside unfiltered, but that requires exhaust at high level above roof height so the portable set is now less potable and also man enough to get it there (ok if you only work in a relatively small area that a flexible tube from the fixed outlet can reach (but if you are in a big factory making minor running repairs then you can’t have pipework everywhere).

So, your 2 minutes welding is going to make that exhaust hanger very very expensive (in fact buy a new car). ALARP does not come into it, they seem to see it as black and white.

So only option just get on and do it, it can’t make things worse for the employee ( Well unless the RPE is not flame retardant!

Having read through all of your comments, i still feel that there is a grey area with regards to the use of LEV outdoors. The HSE bulletin under Action Required states 'Where engineering controls alone cannot control exposure, then adequate and suitable RPE should be provided to control the risk from any residual fume'. It also states 'Make sure suitable controls are provided for all welding activities, irrelevant of duration...this includes welding outside'.

As general ventilation cannot does not achieve the required control measures. Reading between the lines, they are intimating that even if welding outdoors the LEV should be the primary control measure, with RPE as a secondary to protect against any fume that may escape the LEV. Is anyone else of this opinion?

As a large Fabrication company, we have appox. 50 welders on our books undertaking in the main MMA, TIG, MIG welding activities. Financially, I would be looking at costs of around £50-60k just for portable LEV alone. Protecting the workers health is important, but if i can avoid the full costs then i would look to other ideas.

As a company, we do a lot of on-site welding activities on a series of large food manufacturing sites. Welding can be both indoors and out. If we were to use portable LEV and RPE, it would protect the welder and also anyone working near the activity. If i were to use, an air mover for example - the contaminated air would be extracted at source but the contaminant (unfiltered fume) would be move to areas where others could be exposed.

So surely, LEV must be the primary control measure in all situations, whether indoors or out. With RPE as a secondary protective element?

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